Workplace Safety and Health:
Better OSHA Guidance Needed on Safety Incentive Programs
GAO-12-329: Published: Apr 9, 2012. Publicly Released: May 9, 2012.
What GAO Found
Little research exists on the effect of workplace safety incentive programs and other workplace safety policies on workers' reporting of injuries and illnesses, but several experts identified a link between certain types of programs and policies and reporting. Researchers distinguish between rate-based safety incentive programs, which reward workers for achieving low rates of reported injuries or illnesses, and behavior-based programs, which reward workers for certain behaviors, such as recommending safety improvements. Of the six studies GAO identified that assessed the effect of safety incentive programs, two analyzed the potential effect on workers reporting of injuries or illnesses, but they concluded that there was no relationship between the programs and injury and illness reporting. Experts and industry officials, however, suggest that rate-based programs may discourage reporting of injuries and illnesses. Experts and industry officials also reported that certain workplace polices, such as post-incident drug and alcohol testing, may discourage workers from reporting injuries and illnesses. Researchers and workplace safety experts also noted that how safety is managed in the workplace, including employer practices such as fostering open communication about safety issues, may encourage reporting of injuries and illnesses.
In 2010, from its survey, GAO estimated that 25 percent of U.S. manufacturers had safety incentive programs, and most had other workplace safety policies that, according to experts and industry officials, may affect injury and illness reporting. GAO estimated that 22 percent of manufacturers had rate-based safety incentive programs, and 14 percent had behavior-based programs. Almost 70 percent of manufacturers also had demerit systems, which discipline workers for unsafe behaviors, and 56 percent had post-incident drug and alcohol testing policies according to GAOs estimates. Most manufacturers had more than one safety incentive program or other workplace safety policy and more than 20 percent had several. Such programs and policies were more common among larger manufacturers.
Although the Occupational Safety and Health Administration (OSHA) is not required to regulate safety incentive programs, it has taken limited action to address the potential effect of such programs and other workplace safety policies on injury and illness reporting. These programs and policies, however, are not addressed in key guidance such as OSHA's field operations manual for inspectors. OSHA has cooperative programs that exempt employers with exemplary safety and health management systems from routine inspections. One such program prohibits participants from having rate-based safety incentive programs, but guidance on OSHAs other cooperative programs does not address safety incentive programs. Similarly, OSHA inspectors and outreach specialists provide information to employers about the potential benefits and risks of safety incentive programs, but the guidance provided to inspectors in its field operations manual does not address these programs.
Why GAO Did This Study
OSHA relies on employer injury and illness records to target its enforcement efforts. Questions have been raised as to whether some safety incentive programs and other workplace safety policies may discourage workers' reporting of injuries and illnesses. GAO examined (1) what is known about the effect of workplace safety incentive programs and other workplace safety policies on injury and illness reporting, (2) the prevalence of safety incentive programs as well as other policies that may affect reporting, and (3) actions OSHA has taken to address how safety incentive programs and other policies may affect injury and illness reporting. GAO reviewed academic literature, federal laws, regulations, and OSHA guidance; surveyed a nationally representative sample of manufacturing worksites; and interviewed federal and state occupational safety and health officials, union and employer representatives, and researchers.
What GAO Recommends
GAO recommends that OSHA provide guidance about safety incentive programs and other workplace safety policies consistently across the agency's cooperative programs, and add language about safety incentive programs and other workplace safety policies to the guidance provided to inspectors in its field operations manual. OSHA agreed with the recommendations, and noted its plans to address them.
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Recommendations for Executive Action
Comments: According to the Department of Labor, as of October 2013, OSHA had drafted a policy memorandum for companies participating in its cooperative programs, and this guidance, which is similar to the guidance revised in June 2011 for the Voluntary Protection Programs, will be issued in the next 6 months. To date, the Department of Labor has not provided documentation of the issued guidance.
Recommendation: To increase consistency across OSHA's cooperative programs, the Secretary of Labor should direct the Assistant Secretary of OSHA to implement criteria on safety incentive programs and other workplace safety policies across all of its cooperative programs such as the Voluntary Protection Programs (VPP) and Safety & Health Achievement Recognition Program (SHARP). The criteria should be consistent with the most recent VPP guidance memorandum that prohibits employers with safety incentive programs that focus on injury and illness rates from participating in the program.
Agency Affected: Department of Labor
Comments: OSHA intends to update its Field Operations Manual to include a link to a March 2012 memorandum about employer safety incentive and disincentive policies and practices. According to the Department of Labor's October 2013 update, the update has been drafted and is being vetted before being issued. To date, the Department of Labor has not provided documentation of OSHA's revised Field Operations Manual.
Recommendation: To help OSHA inspectors consistently educate employers about the importance of safety culture, the Secretary of Labor should direct the Assistant Secretary of OSHA to add language about key elements of a positive safety culture-and the potential effect of different types of safety incentive programs and other workplace safety policies-to its field operations manual.
Agency Affected: Department of Labor